Pensions Radar - March 2026

The following are forthcoming developments with known or expected dates:

DB scheme funding and investment

DB schemes are required in connection with their next valuation to have a 'funding and investment strategy' for ensuring that benefits can be provided over the long term. After determining or revising such a strategy, trustees have to prepare a 'statement of strategy', to be agreed with the sponsoring employer. All valuations have to be submitted to the Pensions Regulator, whether or not the scheme is in deficit. See WHiP Issues 97 and108.

Complementing these changes is a Pensions Regulator code of practice and updated covenant guidance. The Regulator has also published its 'fast track' parameters which forms part of its guidance on its regulatory approach. There is a digital platform for submitting documents to the Regulator. See WHiP Issues 99, 111 and 113.

Pensions Regulator general code of practice and own risk assessments

The Pensions Regulator has consolidated and updated ten of its codes of practice in a 'General code of practice'.

The General Code also includes new content on scheme governance: this relates to the broadening of internal controls requirements to require occupational pension schemes to "establish and operate an effective system of governance including internal controls", which must be "proportionate to the size, nature, scale and complexity of the activities of the occupational pension scheme". Schemes with 100 or more members also need to undertake an "own risk assessment" of their system of governance at least every three years.

See our briefings on the various aspects of the Code.

Pensions dashboards

The Government has published guidance including a staged timetable for pension schemes and providers to connect to the pensions dashboards ecosystem and be in a position to process 'find' and 'view' requests. The guidance follows the original plan for staged connection dates, ahead of the legal deadline of 31 October 2026. Schemes are required to "have regard to" the guidance. Dates are determined based on scheme type and number of non-pensioner members. See WHiP Issues 105 and 108.

Schemes have been urged to prepare for connection in good time. See our article 10 actions for getting to grips with pensions dashboards.

Corporate directors / failure to prevent fraud / identity verification

Company law statutes include provisions which are of potential relevance to pension scheme trustee companies. These include a ban on corporate directors (i.e. a company acting as a director of another company) and a new offence of failure to prevent fraud. There are likely to be exemptions and transitional measures, details of which are awaited but which may help trustee companies. For example, a trustee (or other) company may be outside the corporate directors ban where it has a director which is a company (for example, an independent trustee firm) but the directors of that firm are all natural persons. See WHiP Issues 112 and 113.

The Economic Crime and Corporate Transparency Act 2023 (ECCTA) also includes new requirements for the identity verification of all directors, LLP members and 'people with significant control' of UK companies and LLPs. See our briefing New UK identity verification requirements under ECCTA.

From 1 September 2025 for the new offence; unknown for the ban on corporate directors

From 18 November 2025 for new directors; a 12 month transition period applies to existing directors and PSCs, during which existing directors will need to confirm they have verified their identity at the same time as they file their next annual confirmation statement.

Targeted support

The FCA has published near-final rules for targeted support in pensions and retail investments and applications for targeted support permissions have opened. See WHiP Issues 117 and 119.

Data protection complaints

Trustees need to ensure that their processes for handling data protection complaints meet new rules under the Data (Use and Access) Act 2025. The new rules are designed to facilitate complaints being made directly to data controllers and include mandatory information requirements and timeframes, including a requirement to acknowledge complaints within 30 days of receipt. Responses must be provided without undue delay. See our Get ready for the new data protection complaints handling rules briefing.

Collective DC expansion

The Government has made regulations to extend collective money purchase pension provision beyond single or connected employer schemes. The regulations set out the regulatory regime for unconnected, multi-employer "whole-life" schemes (i.e. schemes providing accrual and paying benefits). The Pensions Regulator has also consulted on a "new-look" CDC Code of Practice which will extend the existing CDC Code to cover the authorisation and supervision of unconnected multi-employer CDC schemes.

Consultation on whether to introduce decumulation-only (or retirement CDC) arrangements in the future closed on 4 December 2025. The Pensions Minister confirmed at the Pensions UK Investment Conference on 11 March 2026 that legislation to introduce retirement CDC schemes will be published later this year. See WHiP Issue 119

PPF and FAS to provide pre-97 increases

The Pension Schemes Bill contains provision for members of the Pension Protection Fund and Financial Assistance Scheme to receive increases linked to the Consumer Prices Index, capped at 2.5% a year, on benefits earned before April 1997. Increases will be prospective only and will apply where a scheme's original governing documentation contained a right to pre-97 or GMP increases. See WHiP Issue 119.

Pension scheme investment duties

The Pension Schemes Bill contains provision for the Government to give itself power to issue statutory guidance for trustees on how to comply with their duties of investment with a view to giving trustees "added confidence that they can invest in the long-term interests of members and our society". The guidance will be consulted upon and must be published and laid before Parliament within 12 months of the Bill coming into force.

Inheritance tax on lump sum death benefits

The Government is bringing most unused pension funds and death benefits into a person's estate for inheritance tax purposes. Death in service benefits and dependants' pensions will be excluded. The relevant provisions are contained in the newly enacted Finance Act 2026. HMRC will be publishing detailed guidance to support scheme administrators and stakeholders in understanding the new requirements. SeeWHiP Issues 113,117 and 119.